“Recognized And Generally Accepted Good Engineering Practice” (RAGAGEP) – are engineering, operation, or maintenance activities based on established codes, standards, published technical reports or recommended practices (RP) or a similar document. RAGAGEPs detail generally approved ways to perform specific engineering, inspection or mechanical integrity activities, such as fabricating a vessel, inspecting a storage tank, or servicing a relief valve.
That is the official definition of a RAGAGEP from OSHA and EPA, yet we still see the term and its application misused.
What it is NOT…it is not a historical practice at a facility that has been done for many years and “has not killed us yet”. We still see facilities doing tasks and practices that are “the way we have always done it” and can not be traced back to any RAGAGEP and in some cases we can demonstrate there is a RAGAGEP that shows their practice is UNSAFE and violates sound engineering practices.
Facilities need to be very careful in reviewing not only their design of the process, but the operation of the process and maintenance of the process to ensure that ALL aspects of the process are meeting or exceeding RAGAGEP(s). Facilities can piece meal their RAGAGEP(s). By this I mean they can use ASME codes for their pressure vessels, API codes for some vessels, NFPA codes electrical classifications, DIERS for their relief systems, ANSI for their piping, etc.
We are asked so often about a specific piece of equipment and what RAGAGEP should be used, as the facility can not find an API, NFPA, ASME, IIAR code that defines this piece of equipment, how it should be installed, and how often it should be inspected/tested. The VERY FIRST and most basic RAGAGEP for a particular piece of equipment is the “manufacturers recommendation”. This is the very first test OSHA or EPA will use to see if your process is using the right type of equipment and gets to the heart and soul of our Process Safety Information. We should have in our files a spec sheet (or some use the term “cut sheet”) for each type, size, model, etc. for all our valves, pipe, tubing, pumps, instruments, gaskets, vessels, agitators, conservation vents, relief valves, rupture discs, etc. These spec sheets will show that each piece of equipment is rated for the proper pressures and temperatures, made of the correct materials of construction, designed for the application in which we will be using it, etc. and based on the “manufacturer” they are rated/approved and acceptable for use in our process. The spec sheets will often, but not always, contain inspection frequencies and inspection instructions for the maintenance of the equipment. Keep in mind that THE EMPLOYER IS RESPONSIBLE for using the proper equipment in their covered process. I have seen where a plant used the recommendation of a sales/technical person on the type of pump the facility should be using for a specific application. It turns out the pump used components made of an incompatible material that was clearly defined as an unacceptable material in a “spec sheet” (e.g. RAGAGEP) for that specific application in that industry and the facility was cited as a result of this oversight. The facility argued that they relied on the “expert knowledge” of the sales and technical staff of the company that made the pump. OSHA quickly began to go down the road of trying to determine how much influence this “sales/technical person” played in the process safety program for this facility. Do you know where they were going with this???? Contractor Evaluations!!!! If you are allowing outside personnel to make decisions (e.g. spec’ing out equipment) for the process then they could be treated as contractors and this is an awfully close relationship with this sales/technical person – just be careful who you allow to make these types of decisions, both in-house and outside personnel and NEVER LOOSE SITE THAT IT IS THE EMPLOYER WHO IS RESPONSIBLE for process safety. OSHA will NOT cite the company that sold you the equipment, 100% of the burden lies with the facility.
So in closing…
OSHA requires us to define in our Process Safety Information (PSI) what RAGAGEPs we have used to design, operate and maintain our covered process.
1910.119(d)(3)(i)(F) Design codes and standards employed
1910.119(d)(3)(ii) The employer shall document that equipment complies with recognized and generally accepted good engineering practices).
Every piece of equipment, all the way down to the gaskets used in flanges to the outer covering on our critical insulation, has to have supporting documentation that shows it is either meeting a RAGAGEP or the manufacturer’s recommendations in its use and application(s). RAGAGEPs are NOT historical practices that have “kept us safe up to this point”. We need it in writing from a recognized and generally accepted good engineering practice!
PLEASE see the following articles on this topic:
OSHA’s presentation on RAGAGEP Enforcement from 2015 ASSE
OSHA memo on RAGAGEP in Process Safety Management Enforcement
Are we “dumbing” down RAGAGEPs to make OSHA’s job harder?